Data Retention & Deletion Policy
Effective Date: June 2026 · Review Cycle: Annual · Next Review: June 2027
Purpose
This policy defines how Finlighten retains, manages, and deletes consumer data in compliance with applicable privacy laws including the California Consumer Privacy Act (CCPA), Gramm-Leach-Bliley Act (GLBA), and Plaid's developer policies.
Data Categories and Retention Periods
| Data Category | Examples | Retention Period | Storage Location |
|---|---|---|---|
| User Profile Data | Name, email, date of birth | Duration of active account + 30 days post-deletion | BigQuery + Firebase Auth |
| Financial Transaction Data | Transaction history, amounts, merchant names | Duration of active account + 30 days post-deletion | BigQuery |
| Account Balances | Current and available balances | Duration of active account + 30 days post-deletion | BigQuery |
| Plaid Access Tokens | Bank connection tokens | Revoked IMMEDIATELY upon account deletion | BigQuery (encrypted) |
| Authentication Data | Firebase UID, login history | Deleted immediately upon account deletion | Firebase Authentication |
| Sync Logs | Data sync audit trail | 90 days rolling retention | BigQuery |
| Application Logs | API access logs, error logs | 30 days (GCP Cloud Logging default) | GCP Cloud Logging |
Account Deletion Process
When a user requests account deletion, the following steps are executed in order:
Immediate Actions (within 24 hours)
- All Plaid access tokens are revoked via
/item/removeendpoint — bank connections are immediately severed - Firebase Authentication account is deleted — user cannot log in
- User session is terminated across all devices
Within 30 Days
- All transaction records deleted from
fact_bank_transactions - All account records deleted from
dim_accounts - All merchant dimension records attributed to this user deleted
- User profile row deleted from
user_credentials - Dashboard cache deleted from
user_dashboard_cache - Sync log records deleted from
sync_log
Confirmation
- User receives email confirmation that deletion is complete
- Deletion is documented internally for compliance records
How to Request Data Deletion
Users may request account and data deletion by:
- Email: Send a deletion request to [email protected] with subject line "Account Deletion Request"
- In-app: Account deletion option available in Profile Settings (coming soon)
All deletion requests are processed within 30 days of receipt. Users receive a confirmation email when deletion is complete.
Data Portability
Users have the right to request a copy of their data before deletion. Data export requests are fulfilled within 30 days in CSV or JSON format. To request a data export, email [email protected] with subject "Data Export Request".
Third-Party Data Processors
| Processor | Data Processed | Retention Policy |
|---|---|---|
| Plaid | Bank credentials (tokenized), financial institution connections | Governed by Plaid's End User Privacy Policy |
| Google Firebase | Authentication credentials, user sessions | Deleted upon account deletion request |
| Google Cloud Platform | All application data (BigQuery), logs (Cloud Logging) | Deleted per this policy within 30 days of account closure |
Legal Compliance
This policy is designed to comply with:
- CCPA: California Consumer Privacy Act — right to deletion, right to know, right to portability
- GLBA: Gramm-Leach-Bliley Act — financial data privacy and safeguard requirements
- Plaid Developer Policy: Data use and retention requirements for Plaid API customers
Policy Review
This policy is reviewed annually by the Finlighten security and privacy team, and updated when:
- Applicable privacy laws change
- New data categories are collected
- Infrastructure or data storage systems change
- Plaid developer policy requirements are updated
Last reviewed: June 2026 · Next review: June 2027
Contact
For questions about data retention or to submit a deletion or export request:
- Email: [email protected]
- Response time: Within 30 days